ML041680247

Relief Request Third 10-year Pump and Valve Inservice Testing Program

ML041680247
Person / Time
Site:	Kewaunee
Issue date:	07/01/2004
From:	Raghavan L NRC/NRR/DLPM/LPD3
To:	Coutu T Nuclear Management Co
Lyon C, NRR/DLPM, 415-2296
References
TAC MC0488, TAC MC0490, TAC MC0491, TAC MC0492, TAC MC0493, TAC MC0494, TAC MC0495, TAC MC2094, TAC MC2095, TAC MC2096, TAC MC2097, TAC MC2098
Download: ML041680247 (18)

Text

July 1, 2004 Mr. Thomas Coutu Site Vice President Kewaunee Nuclear Power Plant Nuclear Management Company, LLC N490 Highway 42 Kewaunee, WI 54216-9511

SUBJECT:

KEWAUNEE NUCLEAR POWER PLANT - RELIEF REQUESTS FOR THE THIRD 10-YEAR PUMP AND VALVE INSERVICE TESTING PROGRAM (TAC NOS. MC0488, MC0490, MC0491, MC0492, MC0493, MC0494, MC0495, MC2094, MC2095, MC2096, MC2097, AND MC2098)

Dear Mr. Coutu:

By letter dated August 14, 2003, as supplemented February 16 and May 6, 2004, Nuclear Management Company, LLC (the licensee) submitted requests for relief from certain requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the third 10-year interval inservice testing (IST) program at Kewaunee Nuclear Power Plant. The current Code of record for the Kewaunee IST program is the 1989 Edition of the ASME Boiler and Pressure Vessel Code,Section XI, with Appendix I of the ASME OM Code, 1998 Edition through 2000 Addenda, for pressure relief devices.

Based on the information provided in the relief requests, pump relief requests PRR-01 and PRR-03 and valve relief request VRR-02 may be granted on the basis that compliance with the Code requirements is impractical. Therefore, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section, 50.55a(f)(6)(i), the U.S. Nuclear Regulatory Commission (NRC) staff authorizes the IST program alternatives proposed in pump relief requests PRR-01 and PRR-03, and valve relief request VRR-02 for the third 10-year IST interval, which is scheduled to conclude on February 15, 2005. The licensees proposed alternatives provide reasonable assurance of the components operational readiness. Granting these reliefs is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

Valve relief requests VRR-01 and VRR-08 may be granted on the basis that the licensees proposed alternatives to the Code requirements provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the IST program alternatives proposed in valve relief requests VRR-01 and VRR-08 for the third 10-year IST interval, which is scheduled to conclude on February 15, 2005.

T. Coutu For valve relief requests VRR-06 and VRR-07, the NRC staff approves the use of portions of later Code Editions and Addenda pursuant to 10 CFR 50.55a(f)(4)(iv) for the third 10-year interval, which is scheduled to conclude on February 15, 2005, based on incorporation by reference of the 1996 Addenda and the 1998 Edition up to and including the 2000 Addenda of the ASME OM Code.

Pump relief request PRR-02 and valve relief requests VRR-05 and VRR-09 were previously authorized by the NRC and have simply been renumbered by the licensee as a result of revisions to the IST program. Additional NRC approval is not required.

Valve relief request VRR-03 addresses components included in the IST program by the licensee as augmented components. Valve relief request VRR-03 is outside the scope of 10 CFR 50.55a and does not require NRC approval.

The detailed results of the staffs review are provided in the enclosed safety evaluation. If you have any questions concerning this matter, please call Mr. F. Lyon of my staff at (301) 415-2296.

Sincerely,

/RA/

L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosure:

Safety Evaluation cc w/encl: See next page

T. Coutu later Code Editions and Addenda pursuant to 10 CFR 50.55a(f)(4)(iv) for the third 10-year interval, which is scheduled to conclude on February 15, 2005, based on incorporation by reference of the 1996 Addenda and the 1998 Edition up to and including the 2000 Addenda of the ASME OM Code.

Pump relief request PRR-02 and valve relief requests VRR-05 and VRR-09 were previously authorized by the NRC and have simply been renumbered by the licensee as a result of revisions to the IST program. Additional NRC approval is not required.

Valve relief request VRR-03 addresses components included in the IST program by the licensee as augmented components. Valve relief request VRR-03 is outside the scope of 10 CFR 50.55a and does not require NRC approval.

The detailed results of the staffs review are provided in the enclosed safety evaluation. If you have any questions concerning this matter, please call Mr. F. Lyon of my staff at (301) 415-2296.

Sincerely,

/RA/

L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-305

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBLIC PD3-1 Reading WRuland LRaghavan FLyon THarris KPoertner DTerao DWeaver ACRS OGC GHill(2)

PLouden, RIII SReynolds, RIII Accession Number: ML041680247

• SE dated 6/10/04 OFFICE PM:PDIII-1 LA:PDIII-1 SC:EMEB OGC SC:PDIII-1 NAME FLyon THarris DTerao*

RHoefling LRaghavan DATE 06/ /04 06/ /04 6/10/04 06/29/04 07/01/04 OFFICIAL RECORD COPY

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM, THIRD 10-YEAR INTERVAL NUCLEAR MANAGEMENT COMPANY, LLC KEWAUNEE NUCLEAR POWER PLANT DOCKET NO. 50-305

1.0 INTRODUCTION

By letter dated August 14, 2003, Nuclear Management Company, LLC (the licensee), submitted relief requests associated with its third 10-year inservice testing (IST) program plan for pumps and valves for the Kewaunee Nuclear Power Plant. The licensee proposed several alternatives to the requirements of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for its Kewaunee Nuclear Power Plant third 10-year interval IST program. In response to staffs request for additional information, the licensee submitted additional information to the U.S. Nuclear Regulatory Commission (NRC) in letters dated February 16 and May 6, 2004. In its February 16, 2004, letter, the licensee revised pump relief request (PRR) PRR-01 and valve request relief (VRR)

VRR-03 and submitted an additional five relief requests.

As a result of various internal quality assurance audits, as well as NRC inspections that identified potential weaknesses and areas of improvement, the licensee implemented an IST improvement project. The IST improvement program resulted in numerous revisions to the Kewaunee IST program, and the licensee submitted the revised program for NRC review.

Several of the relief requests were previously authorized by the NRC staff for use during the third 10-year IST interval and were simply renumbered by the licensee as a result of the comprehensive design-basis review and revision of the IST program. Relief requests PRR-02 (previously RR-28/ NRC safety evaluation dated June 30, 1997), VRR-04 (previously RR-10A/

NRC safety evaluations dated July 15, 1994 and April 16, 1996), VRR-05 (previously RR-29/

NRC safety evaluation dated September 10, 1998), and VRR-09 (previously RR-24/ NRC safety evaluation dated July 15, 1994) were previously authorized for use during the third 10-year interval IST program and are not addressed in this safety evaluation.

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a does not require NRC approval of alternatives to the Code requirements for components not within the scope of the regulation. The components addressed in relief request VRR-03 are not within the scope of 10 CFR 50.55a. The components have been included in the IST program as augmented components. In position 11 of Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, the NRC indicated that it was acceptable to include components in the IST program even though they are not within the scope of 10 CFR 50.55a. Relief request VRR-03 may be implemented without NRC approval per 10 CFR 50.55a.

NRC evaluation of relief requests PRR-01, PRR-03, VRR-01, VRR-02, VRR-06, VRR-07, and VRR-08 are contained herein. The current Code of record for the Kewaunee IST program is the 1989 Edition of the ASME Boiler and Pressure Vessel Code (ASME Code),Section XI, with Appendix I of the ASME OM Code, 1998 Edition through 2000 Addenda, for pressure relief devices.

2.0 REGULATORY EVALUATION

For Kewaunees third 10-year interval, 10 CFR 50.55a requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year) IST program intervals in accordance with the ASME Code,Section XI and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to paragraphs (a)(3)(i), (a)(3)(ii),or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month IST program interval. In accordance with 50.55a(f)(4)(iv), IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b),

subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for the facility. Section 50.55a permits the Commission to authorize alternatives and to grant relief from ASME Code requirements upon making necessary findings. NRC guidance contained in GL 89-04, provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482, Guidance for Inservice Testing at Nuclear Power Plants.

By letter dated August 14, 2003, the licensee proposed several alternatives to the requirements of the ASME Code for the third 10-year IST interval for Kewaunee Nuclear Power Plant. The Kewaunee third 10-year IST interval began on June 16, 1994, and is scheduled to conclude on February 15, 2005. The program was developed in accordance with the 1989 Edition of the ASME Code,Section XI. The 1989 ASME Code,Section XI, references ASME/ANSI OM Standards Part 1 (OM-1), Part 6 (OM-6), and Part 10 (OM-10) for its IST requirements. The licensee uses Appendix I of the ASME OM Code, 1998 Edition through 2000 Addenda, for pressure relief devices.

The NRCs findings with respect to authorizing alternatives and granting or denying the IST program relief requests are given below.

3.0 TECHNICAL EVALUATION

3.1 Pump Relief Request PRR-01 3.1.1 Code Requirements The licensee requested relief from OM-6, paragraph 5.2, which requires that either flow rate or differential pressure be held constant while measuring the other required parameters. Relief was requested for the following pumps:

Component cooling water pumps 1A, 1B Service water pumps 1A1, 1A2, 1B1, 1B2 3.1.2 Licensees Basis for Requesting Relief The component cooling water and service water pumps perform the safety-related function of providing heat removal from essential safety-related equipment during accident conditions.

The component cooling water pumps operate under a variety of flow rates, differential pressure conditions, and system demands resulting in the inability to easily establish a stable flow rate or differential pressure for evaluation against reference values. Varying the flow rate of the component cooling water pumps is impractical during normal plant operation due to the potential of creating reactor coolant pump transients, which could cause a plant trip. The Code-required test method would be an undue burden in that damage to plant equipment could occur as well as a plant transient/trip.

The service water pumps operate under a variety of flow rates, differential pressure conditions and system demands resulting in the inability to easily establish a stable flow rate or differential pressure for evaluation against reference values. Varying the flow rate of the service water pumps is impractical during normal plant operation due to the potential loss of adequate flow to various components dependent upon service water for cooling water flow and heat removal.

The potential interruption of cooling water flow to these components is burdensome and could result in a reactor transient/trip.

Reference pump curves will be developed and the differential pressure will be compared to that predicted by the reference pump curve for the measured flow rate. Action levels will be established based on the predicted pump curve values. This method of establishing Action levels is consistent with paragraph 6.1 of OM-6. The following elements are used in developing and implementing the reference pump curves:

1.

The data used to develop the pump acceptance criteria curves have been compared to the manufacturer supplied pump curves and the comparison validates proper operation of the pumps.

2.

The instruments used to measure the operating characteristics of the pumps meet the 2 percent accuracy requirements stated in Table 1 of OM-6.

3.

The pump curves are based on six data points.

4.

The six data points chosen are beyond the flat portion of the curve in the region in which the pump is normally operating. The range of data points is within or as near as practicable to design basis flow rates.

5.

Technical Specifications and the updated safety analysis report were reviewed to ensure that the pump curves do not conflict with any operability criteria.

6.

The vibration levels do not vary significantly over the operating range of the pump, therefore, one set of vibration acceptance criteria will be used.

7.

An inservice test is performed on all equipment within the scope of the IST plan following repair, replacement, or performance altering maintenance to determine new acceptance criteria or revalidate the old acceptance criteria prior to returning the equipment to service.

3.1.3 Licensees Proposed Alternative Testing Reference pump curves will be developed and the differential pressure will be compared to that predicted by the reference pump curve for the measured flow rate. Action levels will be established based on the reference pump curve values.

3.1.4 Evaluation OM-6, paragraph 5.2, requires that pump flow rate and differential pressure be evaluated against reference values to monitor pump condition and to allow detection of degradation. The component cooling water pumps and service water pumps operate under a variety of flow rate and differential pressure conditions. Varying the flow rate of these pumps is impractical during normal plant operating conditions because of the potential loss of adequate flow to heat exchangers and the potential of creating plant transients. Imposing the Code requirements on the licensee would be a burden in that interruption of cooling water flow could cause a reactor transient or a trip.

As discussed in NUREG-1482, Section 5.2, the use of pump curves for reference values of flow rate and differential pressure is acceptable when it is impractical to establish a fixed set of reference values. Pump curves represent a set of infinite reference points of flow rate and differential pressure. Establishing a reference curve for the pump when it is known to be operating acceptably and basing the acceptance criteria on this curve can permit evaluation of pump condition and detection of degradation. However, because of a greater potential for error associated with the use of pump curves, Section 5.2 of NUREG-1482 delineates seven elements on the procedures for developing and implementing the curves that should be incorporated into the IST program. The licensees proposed alternative testing is consistent with the guidelines in Section 5.2 of NUREG-1482 and provides reasonable assurance of the operational readiness of the component cooling water and service water pumps.

3.1.5 Conclusion Based on the above evaluation, the staff concludes that the licensees request for relief is granted pursuant to 10 CFR 50.55a(f)(6)(i) on the basis that compliance with the Code requirements is impractical. The licensees proposed alternative testing provides reasonable assurance of the operational readiness of the component cooling water and service water pumps. The staff further concludes that granting the relief will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.2 Pump Relief Request PRR-03 3.2.1 Code Requirements The licensee requested relief from OM-6, paragraph 5.2, which requires that flow rate be measured during quarterly pump testing. Relief was requested for the following pumps:

Safety injection pumps 1A, 1B 3.2.2 Licensees Basis for Requesting Relief The pumps are tested quarterly using a fixed resistence, non-instrumented recirculation path.

GL 89-04, Position 9, Pump Testing Using Minimum-Flow Return Lines With or Without Flow Measuring Devices, identifies that for quarterly pump testing where flow can only be established through a non-instrumented minimum-flow path during quarterly testing and a path exists at cold shutdown or refueling outages to perform a test of the pump under full or substantial flow conditions, the staff has determined that the increased interval is an acceptable alternative to the Code requirements. This is contingent upon pump differential pressure, flow rate, and bearing vibration being measured during the cold shutdown or refueling outage test and that quarterly testing measure at least pump differential pressure and vibration.

3.2.3 Licensees Proposed Alternative Testing Quarterly pump tests will be performed using a non-instrumented recirculation flow path and differential pressure and vibration measurements will be recorded. The pumps will be tested at a substantial flow rate during refueling shutdown with flow rate, differential pressure and vibration measurements recorded.

3.2.4 Evaluation The safety injection pumps can only be tested quarterly using a fixed resistence non-instrumented minimum recirculation flow path. GL 89-04, Position 9, Pump Testing Using Minimum-Flow Return Lines With or Without Flow Measuring Devices, identifies that for quarterly pump testing where flow can only be established through a non-instrumented minimum-flow path during quarterly testing and a path exists at cold shutdown or refueling outages to perform a test of the pump under full or substantial flow conditions, the staff has determined the increased interval is an acceptable alternative to the Code requirements. This is contingent upon pump differential pressure, flow rate, and bearing vibration being measured during the cold shutdown or refueling outage test and that quarterly testing measure at least pump differential pressure and vibration.

It is impractical for the licensee to test the safety injection pumps at power or cold shutdown using the instrumented flow path due to the design of the safety injection system. The licensees alternative meets the requirements of GL 89-04, Position 9, and the guidance contained in NUREG-1482 with respect to quarterly pump testing where flow can only be established through a non-instrumented minimum-flow path during quarterly testing and a path exists at cold shutdown or refueling outages to perform a test of the pump under full or substantial flow conditions. The licensees alternative to test quarterly using a non-instrumented recirculation flow path measuring differential pressure and vibration and testing at a substantial flow rate during refueling shutdown measuring flow rate, differential pressure and vibration provides reasonable assurance of the operational readiness of the safety injection pumps.

3.2.5 Conclusion Based on the above evaluation, the staff concludes that the licensees request for relief is granted pursuant to 10 CFR 50.55a(f)(6)(i) on the basis that compliance with the Code requirements is impractical. The licensees alternative provides reasonable assurance of the operational readiness of the safety injection pumps. The staff further concludes that granting the relief will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.3 Valve Relief Request VRR-01 3.3.1 Code Requirements The licensee requested relief from OM-1, paragraph 1.3.4, which requires that 20 percent of the valves of each type and manufacture be tested within 48 months. The Code further states that this 20 percent shall be previously untested valves if they exist. Relief was requested for the following valves:

CC-401A CC-401B 3.3.2 Licensees Basis for Requesting Relief Appendix I of the OM Code defines a thermal relief application as a relief device whose only overpressure protection function is to protect isolated components, systems, or portions of systems from fluid expansion caused by changes in fluid temperature. These ASME Code Class 3 valves can be classified as thermal reliefs in that they are installed on heat exchangers and discharge to the downstream side of the heat exchanger isolation valves. Therefore, they do not provide any system overpressure protection and only protect the heat exchanger when the isolation valves are closed. Additionally, these valves are located in the component cooling water system such that removal for testing requires a complete system shutdown. This, in turn, requires a full core offload. Therefore, based on the current 18-month refueling outage frequency, a full core offload would be required every other refueling outage to meet the 20 percent tested within a 48 month requirement.

3.3.3 Licensees Proposed Alternative Testing In accordance with ASME OM-1998, Appendix I, paragraph I-1390, and Code Case OMN-2, Thermal Relief Valve Code Case, OM Code-1995, Appendix I, these valves will be tested or replaced once every 10 years, unless performance data indicates more frequent testing or replacement is necessary.

3.3.4 Evaluation Code Case OMN-2 may be used with the 1995 OM Code without NRC staff approval based on the Code Case being approved for use in Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code. The licensees IST program was developed in accordance with the 1989 Edition of the ASME Code,Section XI which references ASME/ANSI OM-1. Code Case OMN-2 is not applicable to OM-1. Therefore, the licensee requested relief from the requirements of OM-1 for thermal relief valves located in the component cooling water system.

The staff has reviewed the activities of the ASME Code committee responsible for the development of Code Case OMN-2, Thermal Relief Valve Code Case, OM Code-1995, Appendix I. The Code Case would require that the valves be tested or replaced once every 10 years, unless performance data indicates more frequent testing or replacement is necessary.

In making their determination to reduce the testing requirements for thermal relief valves, the Code committee evaluated the Nuclear Plant Reliability Data System database to assess the quantity and type of thermal relief valve failures. The Code committee concluded that the low number of failures found supports the 10-year test or replacement frequency and the elimination of sample expansion if failures are discovered during testing. To evaluate the acceptability of applying this Code Case to OM-1, the staff compared the requirements of both Code editions. Thermal relief valves currently fall within the requirements of Class 2 and 3 relief valves for both Code editions. They are not separately defined in either Code edition.

The OM-1995, Appendix I requirements represent a relaxation of the OM-1 requirements in the following areas: (1) elimination of the specific testing schedule for relief valves in the first 10-year interval; and (2) elimination of the requirement to repair or replace all valves which exceed their stamp set pressure by 3 percent or greater. The remaining requirements between the two Codes are technically identical. Therefore, there does not appear to be any conflict in applying Code Case OMN-2 to the OM-1 requirements for the above stated component cooling water valves. Code Case OMN-2 was subsequently incorporated into Appendix I of the ASME OM-1998 Code. On this basis, the staff finds that the licensees alternate testing provides an acceptable level of quality and safety.

3.3.5 Conclusion Based on the above evaluation, the staff concludes that, pursuant to 10 CFR 50.55a(a)(3)(i),

the proposed alternative is authorized on the basis that the proposed alternative provides an acceptable level of quality and safety. This alternative is authorized for the remainder of the third 10-year inservice test interval.

3.4 Valve Relief Request VRR-02 3.4.1 Code Requirements The licensee requested relief from OM-10, paragraph 4.2.1, which requires stroke time testing quarterly. Relief was requested for the following valves:

RHR-8A, RHR-8B SD-3A, SD-3B CVC-7 3.4.2 Licensees Basis for Requesting Relief These valves are not provided with conventional position indication and control switch circuitry, but are provided with a percent open thumb wheel. This control mechanism creates the potential for the inability to acquire repeatable test results when stroke timing the valves, which could result in a failed test and an inoperable valve when the valve is operating acceptably. It is impractical to meet the requirements of the Code for measuring stroke time of these valves because of the design of the valves control systems. Valve exercising by the control station thumb wheel while locally observing the valve to verify the lack of any abnormality or erratic action is an acceptable alternative method to demonstrate valve operational readiness without affecting plant safety or unnecessarily declaring the valve inoperable.

3.4.3 Licensees Proposed Alternative Testing The valves will be full-stroke exercised and verified to exhibit smooth stroke by locally observing the valve and verifying the lack of any abnormality or erratic action. Any abnormality or erratic action experienced during valve exercising shall be recorded in the record of tests, and an evaluation shall be performed regarding need for corrective action.

3.4.4 Evaluation The valves are air operated control valves that perform a safety function as defined within the scope of the ASME OM Code. Because the valves operate as control valves they are not provided with conventional position indication and control switch circuitry to allow stoke time measurement using indicating lights and a stopwatch.

The licensee proposes to full-stroke exercise the valves and observe that valve operation is smooth. Based on the design of the valve control circuitry it is impractical to meet the requirements of the Code for measuring valve stroke time due to the lack of conventional position indication and imposition of the Code requirements would be a burden to the licensee in that design modifications would be required to implement the Code requirements. The proposed alternative testing will provide a means of assuring the operational readiness of the valves.

3.4.5 Conclusion Based on the above evaluation, the staff concludes that the licensees request for relief is granted pursuant to 10 CFR 50.55a(f)(6)(i) on the basis that compliance with the Code requirements is impractical. The proposed alternative testing will provide a means of assuring the operational readiness of the valves. The staff further concludes that granting the relief will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.

3.5 Valve Relief Request VRR-06 3.5.1 Code Requirements The licensee requested relief from OM-10, paragraph 4.3.2.1, which requires that check valves be exercised quarterly except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

OM-10, paragraph 4.3.2.4 allows check valve disassembly every refueling outage where valve full-stroke exercising is not practicable. Relief was requested for the following valves:

MU-311A, MU-311B, MU-311C 3.5.2 Licensees Basis for Requesting Relief These valves are not provided with downstream test connections or position indication. Flow exercising these valves in the reverse direction quarterly during power operation, during cold shutdowns and refueling outages is not practical. Flow exercising requires abnormal alignment of the auxiliary feedwater (AFW) system by the manipulation of various manual valves and requires extensive flushing of the AFW system piping subsequent to closure of the service water supply valves. This activity is necessary to prevent contamination of the condensate storage tank (CST) inventory and also minimizes the potential for chemistry problems in the feedwater system. The intrusion of impure service water into the feedwater system could result in unnecessarily subjecting the steam generators to premature degradation due to inadequate feedwater chemistry. The potential consequences and the actions necessary to perform reverse exercising of the CST supply check valves are undesirable and impractical without a commensurate increase in the level of valve reliability. The only practical means of verifying closure capability of these check valves is by disassembly or by performing a radiographic examination test on the valve body to demonstrate the valve disk is in the closed position.

3.5.3 Licensees Proposed Alternative Testing Full stroke capability of the valves will be verified during refueling outages by disassembly in accordance with the requirements provided in OMa-1996, ISTC-4.5.4(c). As an alternative, closure capability may be verified by non-intrusive methods. Full stroke exercising in the forward direction will be accomplished during quarterly pump testing.

3.5.4 Evaluation The valves for which the licensee requests relief are located in the AFW suction supply lines from the condensate storage tank and function as boundary barrier check valves when the service water system is aligned to the suction of the AFW pumps to prevent the service water supply from being diverted to the condensate storage tank. OM-10, paragraph 4.3.2.1 requires that check valves be exercised at least once every 3 months except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5. As an alternative to demonstrating valve obturator movement, the Code (OM-10, paragraph 4.3.2.4) allows disassembly every refueling outage to verify valve obturator movement. The licensee proposes to implement a sample disassembly program in accordance with the guidelines provided in OMa-1996, ISTC-4.5.4(c).

Staff Position 2 of GL 89-04 allows the implementation of a sample disassembly and inspection plan for groups of identical valves in similar applications. The sample disassembly and inspection plan involves grouping similar valves and testing one valve in each group during each refueling outage. OMa-1996, ISTC-4.5.4(c) allows a sample disassembly examination program to be used to verify valve obturator movement and is consistent with GL 89-04, Position 2. The Code requires that grouping of check valves for the sample disassembly program be technically justified and requires a periodic examination of one valve from the group.

The licensees proposed alternative is consistent with Position 2 of GL 89-04 for the implementation of a sample disassembly and inspection program. OMa-1996, ISTC-4.5.4(c) was incorporated by reference into 10 CFR 50.55a (64 FR 51370), and therefore, is acceptable.

3.5.5 Conclusion Based on the above evaluation, the staff concludes that, pursuant to 10 CFR 50.55a(f)(4)(iv) the licensees proposal to use the OMa-1996, ISTC-4.5.4(c) requirements for check valves MU-311A, MU-311B, and MU-311C is approved for the remainder of the third 10-year inservice test interval.

3.6 Valve Relief Request VRR-07 3.6.1 Code Requirements The licensee requested relief from OM-10, paragraph 4.2.1.1, which requires that active Category A and B valves be tested quarterly, except as provided by paragraphs 4.2.1.2, 4.2.1.5, and 4.2.1.7. Relief was requested for all active Category A and B manual valves.

3.6.2 Licensees Basis for Requesting Relief 10 CFR 50.55a(f)(4)(iv) allows test requirements set forth in subsequent editions of codes and addenda approved for use in 10 CFR 50.55a(b) be adopted provided all related provisions or requirements are met and subject to Commission approval.

Subsection ISTC-3540, Manual Valves, of OMb-2000 establishes a 5-year frequency for manual valve exercising except where adverse conditions may require more frequent exercising. Examples of adverse conditions are harsh service environment, lubricant hardening, corrosive or sediment laden process fluid, or degraded valve components.

Effective October 28, 2002, the 2000 Addenda of the ASME OM Code (OMb-2000) was incorporated by reference into 10 CFR 50.55a(b). 10 CFR 50.55a(b)(3)(vi) clarifies the NRC position that the interval for exercising manual valves may not exceed 2 years when using the 1999 and 2000 Addenda of ISTC-3540.

The manual valves for which the testing applies are exposed to relatively clean process fluids and are located in environments where temperatures should not have an adverse effect on valve operability. Due to the simplicity of manual valve design, and the limited number of failure mechanisms, it is Kewaunee Nuclear Power Plants position to use OMb-2000, ISTC-3540 as further clarified in 10 CFR 50.55a(b)(3)(vi) and exercise manual valves on a 2-year frequency or more frequently when exercised to accomplish a process function if performed routinely.

3.6.3 Licensees Proposed Alternative Testing Manual valves will be exercised in accordance with OMb-2000, ISTC-3540 as further clarified in 10 CFR 50.55a(b)(3)(vi) on a 2-year frequency or more frequently when exercised to accomplish a process function if performed routinely.

3.6.4 Evaluation The licensee proposes to exercise manual valves in accordance with OMb-2000, ISTC-3540 as further clarified in 10 CFR 50.55a(b)(3)(vi) on a 2-year frequency or more frequently when exercised to accomplish a process function if performed routinely.

10 CFR 50.55a(f)(4)(iv) states that IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval. Portions of editions and addenda may be used provided that all related requirements of the respective editions and addenda are met. The 1997 Addenda up to and including the 2000 Addenda of the ASME OM Code (OMb-2000) was incorporated by reference in 10 CFR 50.55a(b) on October 28, 2002 (67 FR 60520), but the NRC placed a limitation to require that manual valves be exercised at a frequency of 2 years, not 5 years as stated in the Code. Therefore, the rule change to 10 CFR 50.55a(b)(3)(vi) set the maximum exercise interval for safety-related manual valves at 2 years, provided adverse conditions do not require more frequent testing.

3.6.5 Conclusion Based on the above evaluation, the staff concludes that the licensees proposed use of later Code requirements in OMb-2000, ISTC-3540, as further clarified in 10 CFR 50.55a(b)(3)(vi),

related to the exercise frequency for manual valves is approved pursuant to 10 CFR 50.55a(f)(4)(iv) based on incorporation by reference of the 1997 Addenda up to and including the 2000 Addenda of the ASME OM Code in 10 CFR 50.55a(b).

3.7 Valve Relief Request VRR-08 3.7.1 Code Requirements The licensee requested relief from OM-10, paragraph 4.3.2.1, which requires that check valves be exercised quarterly except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

OM-10, paragraph 4.3.2.4 allows check valve disassembly every refueling outage where valve full-stroke exercising is not practicable. Relief was requested for the following valves:

SW-1A1, SW-1A2, SW-1B1, SW-1B2 3.7.2 Licensees Basis for Requesting Relief Full stroke exercising these valves in the forward direction with maximum required accident flow quarterly during power operation is not practical due to the potential for equipment damage.

OM-10, paragraph 4.3.2, requires check valves to be exercised nominally every 3 months in a manner that verifies obturator travel to the closed, full-open, or partially-open position as required to fulfill its function. If exercising is not practical during plant operation or cold shutdowns, OM-10, paragraph 4.3.2.2(e), permits the check valves to be full-stroke exercised during each plant refueling outage. As an alternative to check valve exercise testing requirements in OM-10, paragraphs 4.3.2.4(a) and 4.3.2.4(b), paragraph 4.3.2.4(c) permits check valves to be disassembled and inspected every refueling outage to verify operability.

GL 89-04, Position 2, Alternative to Full Flow Testing of Check Valves, provides NRC guidelines to develop a sample disassembly and inspection program where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage. The program involves grouping similar valves and testing at least one valve in each group during each refueling outage. A different valve of each group is required to be disassembled, inspected, and manually full-stroke exercised at each successive refueling outage, until the entire group has been tested.

The valves will be disassembled and inspected on a nominal 18-month frequency, not to exceed 6 years for the group of 4 valves. This valve grouping and inspection frequency is acceptable, as described in GL 89-04, Position 2 and further supported by NUREG-1482, Appendix A. Following check valve disassembly and inspection the check valve will be partial stroke tested.

The valves have been routinely disassembled and inspected during normal at power plant operation as part of the check valve reliability program. The approximate time period for the work associated with the check valve inspection is 10-12 hours, of which 4-5 hours would be wrench time. The time period includes the partial open with flow retest. The task is performed well within the allowed technical specification limiting condition for operation.

Performing this task during refueling outages will add tasks to the refueling outage and potentially extend the refueling work window.

Kewaunee presently utilizes a 12-week maintenance schedule ensuring technical specification compliance during the work planning and execution process with train specific work weeks, and the performance of risk evaluations of emergent work. Additionally, systems and components are monitored as required by the maintenance rule. The probabilistic risk assessment group determined the impact on plant risk associated with performing the disassembly and inspection activity. Assuming each of the individual service water (SW) pumps were unavailable, the highest risk was 5.01E-05/yr with baseline risk at 2.93E-05/yr. This represents a risk of 1.7 times baseline, which is classified as green.

3.7.3 Licensees Proposed Alternative Testing Full stoke capability of the valves will be verified on a nominal 18-month frequency not determined by refueling outages by valve disassembly and inspection in accordance with the guidelines provided in Position 2 of GL 89-04. Partial stroke exercising will be performed during quarterly pump testing.

3.7.4 Evaluation Valves SW-1A1, SW-1A2, SW-1B1, and SW-1B2 are 14-inch, Category C, SW pump discharge check valves. These valves are located at the discharge of each of four respective SW pumps and must open to allow flow to the SW system. The valves also have a function to close to prevent reverse flow and rotation of a non-operating pump. OM-10, paragraph 4.3.2, requires check valves be exercised nominally every 3 months in a manner that verifies obturator travel to the closed, full-open, or partially-open position as required to fulfill its function. If exercising is not practical during plant operation or cold shutdowns, OM-10, paragraph 4.3.2.2(e) permits the check valves to be full-stroke exercised during each plant refueling outage. As an alternative to check valve exercise testing requirements in OM-10, paragraphs 4.3.2.4(a) and 4.3.2.4(b), paragraph 4.3.2.4(c) permits check valves to be disassembled and inspected every refueling outage to verify operability.

GL 89-04, Position 2, Alternative to Full Flow Testing of Check Valves, provides NRC guidelines to develop a sample disassembly and inspection program where the licensee determines that it is burdensome to disassemble and inspect all applicable valves each refueling outage. The program involves grouping similar valves and testing at least one valve in each group during each refueling outage. A different valve of each group is required to be disassembled, inspected, and manually full-stroke exercised at each successive refueling outage, until the entire group has been tested. GL 89-02, Position 2 and OM-10, paragraph 4.3.2.4(c) limits disassembly and inspection of check valves to refueling outages only. The licensee proposed sample disassembly and inspection program grouping criteria are in accordance with Position 2 of GL 89-04 and therefore, provides an acceptable level of quality and safety.

In this relief request, the licensee proposed to disassemble and inspect the check valves on a frequency of once during each operating cycle (18 months) in lieu of once during each refueling outage. The licensees basis for the request is outlined in Section 3.7.2 above. In its review and evaluation of the licensees relief request, the NRC staff found, based on the evaluation of the information provided by the licensee and the following considerations, that: (1) the design of the system is such that the check valve can be disassembled with the unit online; (2) the increase in risk associated with this relief request is small and within the safety margins; and (3) the surveillance requirement will be met for disassembly and inspection of the check valves on a frequency of once during each operating cycle (18 months) with the unit online.

The NRC staff concludes that the licensees proposed sample disassembly and inspection program with the alternative testing frequency of once during each operating cycle (18 months) in lieu of once during each refueling outage provides an acceptable level of quality and safety.

The proposed alternative provides an acceptable method to meet the Code requirements in OM-10, paragraphs 4.3.2.2(e) and 4.3.2.4(c), and the guidelines in GL 89-04, Position 2.

3.7.5 Conclusion Based on the above evaluation, the staff concludes that, pursuant to 10 CFR 50.55a(a)(3)(i),

the proposed alternative is authorized on the basis that the proposed alternative provides an acceptable level of quality and safety. This alternative is authorized for the remainder of the third 10-year inservice test interval.

4.0 REFERENCES

U.S. Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Chapter I, Title 10, Energy, Section 50.55a, Codes and standards.

U.S. Nuclear Regulatory Commission, Guidance on Developing Acceptable Inservice Testing Programs, Generic Letter 89-04, through Supplement 1, April 4, 1995.

U.S. Nuclear Regulatory Commission, Guidance for Inservice Testing at Nuclear Power Plants, NUREG-1482, April 1995.

Letter, T. Coutu, Nuclear Management Company, LLC to NRC, Inservice Testing Program Project, dated August 14, 2003.

Letter, T. Coutu, Nuclear Management Company, LLC to NRC, Inservice Testing Program Project, dated February 16, 2004.

Letter, T. Coutu, Nuclear Management Company, LLC to NRC, NMC Response to NRC Request for Additional Information Regarding the Inservice Testing Program (TAC No.

MC2097), dated May 6, 2004.

Principal Contributor: K. Poertner Date: July 1, 2004

Kewaunee Nuclear Power Plant cc:

John Paul Cowan Executive Vice President &

Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 Plant Manager Kewaunee Nuclear Power Plant N490 Highway 42 Kewaunee, WI 54216-9511 Manager, Regulatory Affairs Kewaunee Nuclear Power Plant N490 Highway 42 Kewaunee, WI 54216-9511 David Molzahn Nuclear Asset Manager Wisconsin Public Service Corporation 600 N. Adams Street Green Bay, WI 54307-9002 Resident Inspectors Office U. S. Nuclear Regulatory Commission N490 Hwy 42 Kewaunee, WI 54216-9511 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Jonathan Rogoff Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Larry L. Weyers Chairman, President and CEO Wisconsin Public Service Corporation 600 North Adams Street Green Bay, WI 54307-9002 David Zellner Chairman - Town of Carlton N2164 County B Kewaunee, WI 54216 Mr. Jeffery Kitsembel Electric Division Public Service Commission of Wisconsin PO Box 7854 Madison, WI 53707-7854